Johnson & Johnson: An ethical analysis of broken trust

Size: px
Start display at page:

Download "Johnson & Johnson: An ethical analysis of broken trust"

Transcription

1 Johnson & Johnson: An ethical analysis of broken trust Karen L. Stewart The Richard Stockton College of New Jersey Whiton S. Paine The Richard Stockton College of New Jersey ABSTRACT For several decades, Johnson & Johnson has been the exemplar of superb ethical behavior in light of the prompt actions it undertook during the 1982 Tylenol cyanide poisoning incident. Now several decades later, J&J s Consumer Product Division has put the company and its reputation in jeopardy by its slow and ineffective response to a series of ongoing problems. This article provides an ethical analysis of those events and addresses the negative impact on Johnson and Johnson s once sterling reputation. Business, ethics, recalls, Johnson & Johnson, reputation, FDA J&J: An ethical analysis, Page 1

2 INTRODUCTION: For several decades, Johnson & Johnson has been the exemplar of superb ethical behavior in light of the prompt actions it undertook during the 1982 Tylenol cyanide poisoning incident that left seven dead in the Chicago area. After the 1982 incident, Tylenol quickly returned to category dominance. A few years later when yet another cyanide-laced Tylenol capsule resulted in the death of a New York woman, Johnson & Johnson and its McNeil subsidiary once again took quick action by only making a compressed and easier-to-detect- tampering version of a Tylenol pill available in the marketplace. The 1986 incident had little impact on sales or J&J s corporate reputation (Davidson & Samghabadi, 1986). Consumer safety and trust were of paramount importance to J&J. The firm validated the utility of their Our Credo philosophy in managerial decision-making during these crisis situations. For several decades thereafter, Johnson & Johnson has consistently and publicly expressed their continuing commitment to this credo. Now several decades later, J&J s Consumer Product Division has put the company and its reputation in jeopardy by its slow and ineffective response to a series of ongoing problems that center on inadequate quality control inside some of the manufacturing plants and slow, reluctant, and ineffective corrective action in response to consumer complaints and growing FDA concerns. The end result is broken trust with consumers and growing damage to J&J s once pristine reputation. The issues arising from recent multiple J&J recalls of Tylenol and other McNeil consumer products are fairly clear (Kimes, 2010, September 6 & 7; Singer & Abelson, 2011, January 15). Here the famous Our Credo oriented corporate culture significantly failed to protect consumers and other stakeholders from both defective products and questionable marketing. Moreover, the more recent problems with Tylenol have raised the broader issue of whether the McNeil problems are, as J&J maintains, unique to that division or are symptomatic of a broader breakdown in J&J s ethical culture. This article will examine what occurred in terms of modern ethical business theory using a framework outlined by Trevino and Nelson (2011) in the 5 th edition of Managing Business Ethics (Straight Talk About How to do it Right). Their work is a major resource for organizational analysis of ethical and unethical corporate behavior. STEP ONE: GATHER THE FACTS On December 17, 2010 a Verified Amended Shareholder Derivative Complaint against nominal defendant Johnson and Johnson was filed at the United States District Court of New Jersey (Civil Action No ). This complaint was filed on behalf of individuals, relief associations and pension fund common stock shareholders who originate from several U.S. states and believe that the corporation and its culture had been harmed by mismanagement at J&J s consumer division, and in particular, by operations affiliated with J&J s subsidiary, McNeil Laboratories Consumer Healthcare unit. Legal issues, per se, will not be addressed since the case is still pending. It is useful to note that this type of suit, unlike most shareholder actions, is not for recovery of lost income but rather an attempt to force the Board of Directors to change the course of the Corporation in order to protect future income. Instead the focus herein will be on the series of events that led to the filing of this case and a corresponding ethical analysis. However, this case raises the very basic question of whether the Our Credo based corporate culture of J&J has changed throughout the corporation or only at the McNeil subsidiary. J&J: An ethical analysis, Page 2

3 A New York Times article (Singer & Abelson, 2011) reported that in 2010 the McNeil Consumer Healthcare unit of J&J recalled about 288 million items including adult and children's pill medications and around 136 million bottles of liquid Tylenol, Motrin, Zyrtec and Benadryl for infants and children. The FDA stated that some of the products included in the recalls may contain a higher concentration of active ingredients, others may contain inactive ingredients that may not meet internal testing requirements, and others may be contaminated with bacteria or contain tiny particles of wood, glass, or metal. (Civil Action No ). As recently as mid- February 2011 J&J recalled 70,000 syringes preloaded with its injectable anti-psychotic drug, Invega, due to cracked syringes and possible infection risk (Loftus, 2011). It also recalled its Securestrap Hernia product due to non-sterile packaging, and 395 injection pens in the U.S. and Germany which were pre-loaded with the rheumatoid arthritis drug, Simponi, due to possible dosage problems. Specific recalls during 2010 alone as delineated in the shareholders case (Civil Action No ) are as follows: Tylenol 8 Hour Caplet (50 count); about 128,000 bottles; October 18, 2010; due to musty or moldy smell emanating from the pills Benadryl Fastmelt tablets; 4,000,000 packages; Motrin caplets (800,000 packages); Extra Strength Rolaids and Mylanta products (71,000 caplets); November 15, 2010; due to manufacturing insufficiencies (outside of specifications) Tylenol Cold Multi-Symptom liquid medication (9,000,000 bottles); November 24, 2010; due to the presence of alcohol from flavoring agents noted as an inactive ingredient on the package but not on the front panel Mylanta (12,000,000 bottles) and AlternaGel liquid antacid (about 85,000 bottles; November 29, 2010 in order to update the labeling to note the presence of small amounts of alcohol (less than 1%)) ) Acuvue TruEye contact lenses (about 492,000 boxes); December 1, 2010; due to irritation and pain among users as a result of higher-than-expected expected levels of a type of acid used in the manufacturing process and not fully removed in the rinsing process Rolaids (over 13,000,000 packages); December 9, 2010; due to metal and wood particles in the products An online search will reveal that there were earlier recalls including one in April 2007 when bacteriological contamination led to a recall of all previously produced lots of the newly released children s Listerine Cool Blue mouthwash. The bacteria involved were highly antibiotic resistant and potentially deadly to children with impaired immune systems. In November 2008 there was a recall of Infants Mylicon Gas Relief Dye Free Drops (a Merck/J&J joint venture at their Lancaster, PA plant) due to possible contamination by metal fragments (2008, Reuters, November 10). The various recalls cited above are described to illustrate that there have been ongoing problems connected to the production of J&J s consumer products. Those problems potentially impact on the potency, purity, consistency and safety of a wide variety of over-the-counter drugs for adults and children. What makes these recalls particularly puzzling is the effort J&J has made to position itself as the leading supplier of medications to infants and children. Marketing ethicists have noted that companies have particular responsibilities in protecting such vulnerable segments in the marketplace (Brenkert, 2008; Murphy, Laczniak & Klein, 2005). It seems that J&J has had ongoing manufacturing and related quality control problems at most of its McNeil manufacturing plants, including the Fort Washington, Pennsylvania facility J&J: An ethical analysis, Page 3

4 and the Las Piedras, Puerto Rico facilities in particular (Sharfstein, 2010). Moreover, it appears that J&J was not in compliance with current Good Manufacturing Practices (cgmp). As alleged in the legal case that was filed in New Jersey, the J&J board of directors (the Board ) was warned, specifically and repeatedly over a number of years, that J&J s drug and medical device manufacturing and marketing practices represented systemic and widespread violations of the law. (Civil Action No , p.2) The legal case further states there were, six FDA warning letters and additional violation notices specifically identifying unlawful marketing practices or public health and safety violations and demanding that J&J cease the identified practices and all similar misconduct. (Civil Action No , p. 2) J&J closed the Fort Washington plant in April 2010 for a $100 million overhaul (Singer & Abelson, 2011). These types of breaches are not trivial because they violate the core of the voluntary FDA surveillance system which is intended to protect public health and well-being. Another concern relates to an earlier problem the so-called phantom recall of Motrin from retail stores that occurred around June J&J s McNeil subsidiary hired a contractor to remove approximately 88,104 packages of that medication from stores due to a concern with how the pills dissolved (U.S. Food & Drug Administration, 2010). Members at a Congressional hearing were informed the subcontractor had been instructed by J&J to tell employees that there was to be no mention of a recall. Instead the subcontractors employees were to simply act like regular customers and buy the medication (CSCS, 2010). Needless to say, concerns have been raised about the surreptitious nature of this approach to a medication concern. The FDA did contact McNeil and asked it to remove the remaining product from store shelves. The firm did so in July 2009, eight months after learning of the problem with Motrin (Hensley, 2010). The basic problem here is that the FDA has no statutory authority to force recalls and relies on companies like J&J voluntarily informing the agency of such actions. That system cannot operate effectively ectively to protect public health if companies conduct phantom recalls. Defects and recalls is one of 16 possible crisis management categories and accounted for 6% of news reports in 2010 (Institute for Crisis Management, 2011). In that report they also conclude that, since 2001, the majority of crises were caused by managers. Moreover, the ICM reported that pharmaceuticals were the most crisis prone industry in 2004 (Institute for Crisis Management, 2005). A review of their annual reports since that time finds that industry continues to be listed in the top ten in subsequent years. In the 2011 report, pharmaceuticals were number six on the list and, across all industries J&J was listed as drawing the most headlines for defects and recalls. As previously noted, the FDA essentially operates a cooperative system since they lack the statutory authority to demand recalls or removals from the marketplace. This voluntary system depends on companies discharging their ethical obligation to protect public health. J&J s problems, particularly their phantom recall, have led to proposed legislation, and a recent survey from within the industry found that 86% of the respondents indicated that the FDA should have the power to force drug recalls just as it does for defective food products (Pellek, 2011). Although this legislation is undesirable to companies given the cost involved with recalls and their loss of control over the process, the vote may reflect a perception within the industry that highly publicized recalls potentially damage the reputation of the industry as a whole. Other problems in various divisions of J&J have also surfaced in recent years. On August 24, 2010 the FDA ordered J&J to stop sales of an orthopedic device (Corail Hip System) because the firm was marketing it for an unapproved use (Civil Action No ). A much larger problem here is the recall of over 90,000 possibly defective hip replacements which J&J: An ethical analysis, Page 4

5 represents a potential liability to J&J of over $1 billion (Litigation and Settlement News, 2011, February 3). Also, Risperdal, approved by the FDA for treating psychotic disorders in adults, was being illegally marketed and promoted for off-label uses. It is also alleged that Topamax, an anti-epileptic drug, which showed evidence of serious side effects in clinical trials was being marketed for a host of ailments and diseases for which FDA approval had not been granted (Civil Action No ). While off label use of pharmaceuticals is a fairly common practice in the art of medicine, drug manufacturers are not permitted to directly promote to physicians off- label uses (Johns Hopkins, 2011 June). Furthermore, Natrecor, which was approved by the FDA to treat patients with congestive heart failure and related breathing problems was being infused into patients in outpatient settings and J&J allegedly encouraged the growth of these types of facilities for administering the infusions despite risks to patients and a lack of scientific evidence that regularly scheduled infusions was safe or effective (Civil Action No ). A New York Times article (2005, August 9), indicated that J&J was asked to begin warning doctors against the drug s use in outpatients, a treatment that was not approved by the FDA; however, that use was known to be a big money maker for the firm. Another concern revolved around the sale and marketing of biliary stents. Biliary stents were designed for cancer patients. The purpose of the stent is to aid drainage in the bile duct. J&J has been accused of funding studies for off-label use (e.g., peripheral vascular disease) and providing unsolicited marketing and promotional literature to doctors for unapproved use of those stents. It is further alleged that sales representatives were given mandatory quotas and bonuses for selling certain numbers of stents for off-label use and that sales representatives provided physicians with manuals that showed them how to falsely file for reimbursement for off-label use of the device (Civil Action No ). What can be gleaned from these facts is that J&J s actions (or lack thereof) have directly resulted in a series of problems that have negatively impacted the reputation of the firm. Unlike the Tylenol situation in 1982, these issues were internal and caused by management lapses at J&J. Moreover, it appears that J&J has been slow to respond to a myriad of problems: that their responses have been largely guided by considerations of legal vulnerability, and that these developments may represent a major change from what consumers have come to know and expect from a company that has been held in high regard by the buying public for decades. Those expectations reflect over 30 years of successful public relations structured around J&J s continuing commitment to their famous Our Credo. On their Web site they clearly state, The values that guide our decision making are spelled out in Our Credo. Put simply, Our Credo challenges us to put the needs and well-being of the people we serve first. ( paragraph 1). STEP TWO: IDENTIFY THE PERTINENT ETHICAL ISSUES/POINTS OF ETHICAL CONFLICT The primary ethical problem that surfaces is that J&J faces major challenges within all three of its business groups (pharmaceuticals, medical devices and consumer products). Many of these problems represent significant potential or actual harm to consumers. In particular the firm has been accused of not addressing the quality control concerns in a timely fashion, and of inadequate responsiveness to consumer and patient complaints arising from product problems. Also, it has been alleged that the firm has continued to engage in aggressive (and at times, illegal) marketing efforts to sell those medications and devices in order to keep their sales and J&J: An ethical analysis, Page 5

6 profits high with little regard for the well-being of consumers and patients. A recent analysis found over 60 ethical issues raised by recent J&J actions (2011, Paine). STEP THREE: IDENTIFY THE RELEVANT AFFECTED PARTIES One relevant element relates to stakeholder theory. Stakeholders are individuals and entities that have a vested interest in the firm. It is important to identify who will be harmed by actions undertaken by the firm and to what extent. In this case, key stakeholders would include consumers, the medical community, the FDA, shareholders, J&J employees, and J&J management and its Board of Directors. The situation at J&J is relatively unique since in 1982 they were lauded for appropriately representing the interest of all relevant stakeholders and in 2010 were excoriated for the opposite. Customers, medical personnel, J&J employees and executives, regulators and legislators all have expressed a deep disappointment at recent company actions. Even business professors and ethicists no longer have J&J as an immediate answer to the question, "Can you name one ethical company?" The only happy group of stakeholders appears to be the lawyers. More specifically J&J has long had a credo in place that identifies and prioritizes their primary stakeholders. In part it states the following key principles: We believe our first responsibility is to the doctors, nurses, and patients, to mothers and all others who use our products and services. In meeting their needs, everything must be of high quality We are responsible to our employees, the men and women who work with us throughout the world We are responsible to the communities in which we live and work Our final responsibility is to our stockholders. Businesses must make a sound profit. We must experiment with new ideas. Research must be carried on, innovative programs developed and mistakes paid for. New equipment must be purchased, new facilities provided, and new products launched. Reserves must be created to provide for adverse times. When we operate according to these principles, the stockholders should realize a fair return. (as cited in Hartley, 2005, p. 311) In a New York Times article Meier (2010, December 17, p. B1) quoted Dr. Stephen Graves, the Director of Australia s orthopedic database as stating, When it is clear to the orthopedic community that a company has not been honest, that is a problem. I think J&J has a major issue. The company initially exacerbated this concern by claiming that the problem was not with the product, but rather with how it was inserted by surgeons. A confidential witness in the New Jersey shareholders case (Civil Action No ) indicated that there was a clear direction to sell Risperdal (approved by the FDA to treat psychotic disorders in adults) to elderly patients for treatment of dementia and Alzheimer s disease, both unapproved uses of the drug. Another complaint in that legal document is that Topamax (an anti-epileptic drug) was being aggressively marketed as a potential treatment for a number of conditions for which there was not any valid scientific evidence supporting its safe use. It is further alleged that J&J trained its sales force to mislead physicians into believing that such evidence existed (Civil Action No ). Another concern revolved around J&J supposedly encouraging the establishment of infusion clinics that would provide outpatient infusions of Natrecor. According to an article published in The New York Times (2005, August 9) this drug was not approved by the FDA to be used in outpatient settings and should have been strictly limited to the treatment of acutely ill patients in hospitals. However, use of this drug in outpatient facilities had turned into a big money maker for J&J. Another money-related issue concerns the equipment that was being used J&J: An ethical analysis, Page 6

7 at the Fort Washington plant. A confidential witness stated that he had learned that certain equipment needed to be replaced but upper management refused to do so due to cost-saving measures (Civil Action No ). It should also be noted that the ORA FOAI Electronic Reading Room> McNeil Healthcare section of the FDA website documents multiple cgmp violations at the main McNeil production facilities dating back over ten years. Although there have been no reported deaths from the various OTC situations cited above, J&J has engaged in activities that represent a serious breach of trust with its stakeholders. It appears that J&J was attempting to put its stockholders first by engaging ging in activities that were designed to fatten the bottom line but in an ironic twist, it is stockholders who are becoming vocal about short-sighted sighted practices and the apparent lack of appropriate action that have seriously damaged the company name and reputation. Also, it appears that J&J, particularly at its McNeil subsidiary and probably at Dupuy and several other operating units as well, may have lost sight of long-held and cherished corporate values. Key stakeholders were clearly let down by J&J. J. Physicians and others in the medical community were misled by some of the information that was provided and/or told to them. Parents, who are responsible for making decisions in the best interests of their children, found themselves administering medication to them that did not comport with current Good Manufacturing Practices. Pharmacists and other suppliers lacked desired products as did brand loyalists. Adults (particularly the elderly), suffering from various maladies, must rely on the wisdom and guidance of members of the medical community and companies like J&J. Shareholders, in turn, suffered from short-sighted sighted decisions made by managers and the Board of Directors. Employees livelihoods were put at risk by the temporary closing of the Fort Washington plant and subsequent remuneration restrictions throughout J&J because of the reduced sales of the consumer operating units. Plus, the overall profitability and reputation of a once stellar company was damaged. In 2010 alone consumer product sales were $1.2 billion under the 2009 sales figure. That represents an abrupt reversal of the past pattern of increases as documented in multiple J&J annual reports. It is said that companies are able to build up trust accounts (Trevino & Nelson, 2011). Much like a bank account where deposits can be made and withdrawn, J&J made a substantial deposit to its trust account through the proper handling of the 1982 Tylenol poisoning incident. However, recent actions (or lack thereof), have contributed to withdrawals from J&J s trust account. As Trevino and Nelson (2011) note, trust has both economic and moral value. STEP FOUR: IDENTIFY THE POSSIBLE CONSEQUENCES OF ALTERNATIVE COURSES OF ACTION Traditional utilitarian theory suggests that decision-making ought to be conducted in such a way that total benefits exceed total costs by the maximum amount possible (e.g., the greatest good for the greatest number of stakeholders). This approach to decision-making is often used in situations involving eminent domain (e.g., the cost of displacing homeowners as compared to the benefit to society of highway construction proceeding in a given area). However, as noted by Trevino and Nelson (2011, p. 41), it is often difficult to obtain the information required to evaluate all of the consequences for all stakeholders who may be directly or indirectly affected by an action or decision. Moreover, it can be difficult to quantify the extent of the benefits and costs. Pharmaceutical recalls can have multiple causes (Priporas & Vangelinos, 2008) and much of the relevant information is proprietary and unavailable. What is clear is that both the immediate and the longer term costs to almost all stakeholders of recent J&J actions far outweigh J&J: An ethical analysis, Page 7

8 the relatively limited cost benefits gained by not taking needed corrective action in a timely and effective manner. For example, the complete renovation of the Fort Washington production facility will cost over $100 million. The 2011 J&J Annual Report (released in 2011) indicated that J&J consumer sales dropped over $1 billion from Major additional costs were incurred in the various recalls. A real issue here is whether or not J&J s reservoir of goodwill will be drained to the point where there are continuing profit reductions associated with further reduced sales. There will be a variety of outlays associated with plant renovations, use of outside consultants mandated by the FDA under the Consent Decree, marketing expenditures as brands return to crowded shelves, and a growing number of legal proceedings. The foregoing information clearly indicates that a host of individuals were affected by inaction and slowness to respond by company officials. Vulnerable groups such as children, senior citizens, and others experiencing health problems were put at risk. Fortunately, however, there were no deaths clearly linked to cgmp violations but that is not true for pharmaceuticals and medical appliances. Consequently, J&J had an ethical responsibility to respond more quickly with respect to ensuring its facilities were adhering to accepted quality control standards, equipment should have been replaced and/or monitored more regularly, and recalls should have been implemented much sooner than they were. Moreover, problems with over-the-counter medications would not have occurred had the firm worked more closely with the FDA to resolve the issues documented during recent site visits. STEP FIVE: IDENTIFY RELEVANT OBLIGATIONS Relevant obligations center on duties. The question becomes one of asking to what extent the firm had a duty to investigate and correct problems (1) that were occurring inside its plants and (2) with the marketing efforts of the operating units of a highly decentralized corporation. Did J&J have an obligation to inform doctors, nurses, and others in the medical community sooner than they did and more fully? To what extent did the firm have an obligation to notify the media and consuming public about the problems? Did J&J have a moral as well as a legal duty to respond appropriately to FDA warning letters and to voluntarily recall affected products or remove them entirely from the market? Did J&J have a responsibility to train its salespeople e to adhere to ethical marketing practices? Did J&J have an obligation to ensure that its marketing materials did not mislead? An analysis of Johnson and Johnson's own public statements and documents used to train and direct personnel indicates that they were committed to discharge all of these duties in an exemplary fashion. However, they apparently did not do so in accordance with their stated values. STEP SIX: IDENTIFY YOUR RELEVANT COMMUNITY STANDARDS THAT SHOULD GUIDE YOU AS A PERSON OF INTEGRITY The relevant community includes the various stakeholders mentioned in J&J s credo plus the pharmaceutical industry in general and the FDA in particular. It should be noted that while other pharmaceutical firms have faced similar problems in the same timeframe, the situation at McNeil and Johnson & Johnson stands out in terms of the number and variety of problems. Big Pharma in general would likely not be pleased with additional scrutiny (and possibly more government regulation) of its operations as a result of J&J s missteps. Patients and the medical community at large would expect a firm such as J&J, that has made its name and reputation on caring for the vulnerable (babies and children in particular), to consistently and reliably produce J&J: An ethical analysis, Page 8

9 high quality products and remove defective products rapidly from the marketplace. They would also expect a quick and thorough investigation when problems arose and fast and effective corrective action. They would expect the firm to engage in whatever activities need to be undertaken, despite attendant costs, to ensure that their well being is being protected. Trust was earned and enhanced during the 1980s when J&J and its McNeil subsidiary were so quick to recall Tylenol due to cyanide poisoning incidents that resulted in multiple deaths. In the aftermath of those events, J&J was instrumental in developing tamper-resistant resistant packaging that is now the industry standard. One has to wonder what has changed inside some operating units and possibly throughout this company since those days. A major limitation here is that Johnson & Johnson has imposed very strict limitations on the amount of information available from within the firm during recent years. This makes any analysis of the company situation preliminary until more information from various lawsuits and company documents pertinent to discovery become available. STEP 7: CHECK YOUR GUT A gut decision should have been an easy call. When OTC products have a moldy smell, when wood, metal, and other particles are turning up in medications that are designed to be ingested, when individuals have to undergo a repeat of surgical procedures to replace defective medical devices, there is no need for second guessing whether something needs to be done to address those situations. At the very least, inspections and corrective action needed to be carried out in the problem facilities. Products, particularly surgical devices should not be released into the market based on faulty or inadequate scientific testing. Under circumstances when medical devices are released in good faith but problems arise, at the very least, the medical community ought to be informed so they and their patients can make appropriate decisions. When the FDA issues warning letters, appropriate responses are expected. Most employees want to feel good about themselves and the firms they work for. Good, responsible ethical training should be provided and employees es should be rewarded (or punished) based on adherence to (or disregard of) the code of conduct that is in place. The Our Credo and J&J s own policies and procedures and training activities all could be rapidly mobilized to support the above mentioned actions. STEP 8: WHAT WILL YOU DECIDE? It is clear that J&J has made withdrawals from its trust bank in recent years. The decision should have been made to take corrective action much sooner than what occurred. However, the series of problems that have plagued J&J in recent years do not rise to the level of concern that was raised during the Tylenol poisonings so full-blown media attention by top officials at J&J, and the media, was not warranted or expected. However, it is difficult to understand why this once stellar firm allowed so many problems to continue and for so long. It is also unclear why J&J was so unresponsive to warning letters issued by the FDA. Most marketing professionals know that it can take decades to establish a name and reputation of trust but only one or a few brief lapses to destroy a company image. There already are some preliminary indications from different surveys that have been undertaken that indicate J&J s good corporate reputation is beginning to wane. For example, J&J ranked #4 in the Fortune Magazine s 2009 list of the World s Most Admired Companies ( However, in the 2010 ratings J&J: An ethical analysis, Page 9

10 J&J had dropped to #17 ( The continuing negative publicity associated with the events described herein is likely to have a cumulative negative impact on Johnson and Johnson s once sterling reputation. In turn there are likely to be negative impacts on sales and profitability. REFERENCES Brenkert, G. G. (2008). Marketing Ethics. Blackwell, Malden, MA. Civil Action No (FLW).Case 3:10-cv FLW-DEA Document 94 Filed 12/17/10, pp CSCS Motrin purchase project (2009, June 12). Committee on Oversight and Government eform website. 10_J&J_Recall/Document_1.pdf. Davidson, S. & Samghabadi, R. (1986, February 24). A replay of the Tylenol scare. Fortune (2010, March 22). World s most admired companies. Retrieved from Fortune (2011, March 21). World s most admired companies. Retrieved from Hartley, R. F. (2005). Business Ethics: Mistakes and Successes, 1 st ed., Wiley. Hensley, S. (2010, May 27). FDA: Johnson & Johnson concealed Motrin recall. NPR, Institute for Crisis Management (2005, May). Annual ICM crisis report: News coverage of business crises during (1). Retrieved from Institute for Crisis Management (2011, May). Annual ICM crisis report: News coverage of business crises during (1). Retrieved from Johns Hopkins (2011, June). The Johns Hopkins medical letter: Health after 50, 23(4). Johnson & Johnson (n.d.). Our Credo Values. Retrieved from paragraph 1. Kimes, M. (2010, September 6). Why J&J s headache won t go away. Fortune, 162(4), pp , 106, 108. Also on CNNMoney.com and retrieved from Kimes, M. (2010, September 7). Johnson & Johnson CEO Bill Weldon s painful year. CNNMoney.com. Retrieved from une/index.htm. Litigation and Settlement News (2011, February 3). Johnson & Johnson to set aside almost $1 billion for DuPuy hip replacement litigation. Retrieved from Loftus, P.(2011, February 16). J&J J recalls 70,000 Invega Syringes. Retrieved at Meier, B. (2010, December 17). The implants loophole, p. B1. The New York Times. Retrieved from J&J: An ethical analysis, Page 10

11 Murphy, P. E., Laczniak, G. R., Bowie, N. & Klein. T. A. (2005). Ethical Marketing. Pearson/Prentice Hall, Upper Saddle River, NJ. Paine, W. S.(2011, June 5). Tylenol 21 st Century Controversies. Poster at the Marketing and Public Policy Conference, Washington, D.C. Pellek, A. (2011, February 3). Pharm TechTalk. PharmTech poll shows readers favor expanding FDA s recall power. Retrieved from poll-shows-readers-favor-expanding-fdas-recall-power/. Priporas, C., & Vangelinos, G. (2008). Crisis management in pharmaceuticals: Evidence from Greece. International Journal of Pharmaceutical and Healthcare Marketing, 2(2), pp Reuters (2008, November 10). J&J, Merck recall Mylicon infant anti-gas drops. Retrieved from Sharfstein, J. M., (2010, September 10). Johnson and Johnson s recall of children hildren s Tylenol and other children s medicines and the phantom recall of Motrin (Part 2), FDA testimony. Retrieved at Singer, N., & Abelson, R. (2011, January 16). Can Johnson & Johnson get its act together?, p. BU1. Retrieved at johnson.html?r=2&ref=bus. Trevino, L. & Nelson, K. (2011). Managing business ethics (Straight talk about how to do it right), 5 th ed., Wiley, Danvers, MA. U.S. Food & Drug Administration (2010). Motrin recall: Delay in reporting material information, 10_JandJ_Recall/ _Meeting.pdf, p.7, accessed via Scott Hensley, FDA: Johnson & Johnson concealed Motrin recall. J&J: An ethical analysis, Page 11

Life (or is it really?) Under a Consent Decree

Life (or is it really?) Under a Consent Decree Life (or is it really?) Under a Consent Decree Steven Niedelman Lead Quality Systems & Compliance Consultant King & Spalding LLP 1700 Pennsylvania Ave., NW Washington, DC 2006 202-626-2942 sniedelman@kslaw.com

More information

The spokesperson for Baxter, the manufacturer of the two blood thinners, said it was not their fault:

The spokesperson for Baxter, the manufacturer of the two blood thinners, said it was not their fault: Baxter case In a 60 Minutes Report on March 16, 2008, Dennis Quaid and his wife Kimberly reported on the near death of their newly born twins. The twins had been taken to the hospital a few days after

More information

A Tale of Two Tylenols

A Tale of Two Tylenols A Tale of Two Tylenols A Case Study of Johnson & Johnson Credo and Corporate Culture presented by: Professor Paul Fiorelli, J.D., M.B.A., C.C.E.P. Co-Director, Cintas Institute for Business Ethics, Xavier

More information

We have carefully reviewed your questions and the recent promotion for your program on the ABC website.

We have carefully reviewed your questions and the recent promotion for your program on the ABC website. 23 May 2014 Mr P Cronau Senior Producer, Four Corners, The ABC, GPO Box 9994, Sydney NSW 2001. Dear Mr Cronau, We have carefully reviewed your questions and the recent promotion for your program on the

More information

J&J Sold Vaginal Mesh Implant Without US Regulatory Approval

J&J Sold Vaginal Mesh Implant Without US Regulatory Approval PHARMACEUTICALS EXPORT PROMOTION COUNCIL (Set up by Ministry of Commerce & Industry, Govt., of India) Date: 21 st March, 2012 J&J Sold Vaginal Mesh Implant Without US Regulatory Approval Johnson & Johnson

More information

Question 5. After the trial, Attorney sent a $500 gift certificate to Doctor, with a note thanking her for recommending that Peter call him.

Question 5. After the trial, Attorney sent a $500 gift certificate to Doctor, with a note thanking her for recommending that Peter call him. Question 5 Attorney mailed a professional announcement to several local physicians, listing his name and address and his area of law practice as personal injury. Doctor received Attorney s announcement

More information

Blowing the Whistle on Nuclear Safety Lapses: Federal Whistleblower Protections Act At A Glance

Blowing the Whistle on Nuclear Safety Lapses: Federal Whistleblower Protections Act At A Glance Blowing the Whistle on Nuclear Safety Lapses: Federal Whistleblower Protections Act At A Glance by David J. Marshall 1 Katz, Marshall & Banks, LLP www.kmblegal.com Following decades of opposition from

More information

Blowing the Whistle on Accounting Fraud: The Sarbanes-Oxley Whistleblower Protections Act At A Glance

Blowing the Whistle on Accounting Fraud: The Sarbanes-Oxley Whistleblower Protections Act At A Glance Blowing the Whistle on Accounting Fraud: The Sarbanes-Oxley Whistleblower Protections Act At A Glance A White Paper for Finance Professionals by David J. Marshall and Nicole J. Williams 1 Katz, Marshall

More information

CRISIS MANAGEMENT: Practice Series. The Economy, Security and Coping with the Unexpected. Anton R. Valukas. Robert R. Stauffer. Thomas P.

CRISIS MANAGEMENT: Practice Series. The Economy, Security and Coping with the Unexpected. Anton R. Valukas. Robert R. Stauffer. Thomas P. Practice Series CRISIS MANAGEMENT: The Economy, Security and Coping with the Unexpected Anton R. Valukas Robert R. Stauffer Thomas P. Monroe 2002 JENNER & BLOCK, LLC ALL RIGHTS RESERVED Offices One IBM

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant William D. Marler Marler Clark LLP PS 01 Second Ave, Suite 00 Seattle, WA 1-0 Ph: IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE DOROTHY H. PEARCE, vs. Plaintiff,

More information

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 1 TABLE OF CONTENTS 1. INTRODUCTION 3 2. WORK ENVIRONMENT 3 2.1 Discrimination & Harassment 3 2.2 Privacy of Personal Information 3 2.3 Internet

More information

INJURY LAW ALERT WINTER 2006/2007 ISSUE WHAT IS MEDICAL MALPRACTICE?

INJURY LAW ALERT WINTER 2006/2007 ISSUE WHAT IS MEDICAL MALPRACTICE? INJURY LAW ALERT WINTER 2006/2007 ISSUE WHAT IS MEDICAL MALPRACTICE? Medical malpractice is a broad term used to describe a number of different kinds of lawsuits brought against doctors and hospitals.

More information

HP0868, LD 1187, item 1, 123rd Maine State Legislature An Act To Recoup Health Care Funds through the Maine False Claims Act

HP0868, LD 1187, item 1, 123rd Maine State Legislature An Act To Recoup Health Care Funds through the Maine False Claims Act PLEASE NOTE: Legislative Information cannot perform research, provide legal advice, or interpret Maine law. For legal assistance, please contact a qualified attorney. Be it enacted by the People of the

More information

Information for Worker s Compensation Clients

Information for Worker s Compensation Clients Information for Worker s Compensation Clients Overview of the Worker s Compensation Act Indiana Worker s Compensation cases are governed by a State law known as the Worker s Compensation Act. The legislature

More information

Principles of Corporate Governance

Principles of Corporate Governance Principles of Corporate Governance Johnson & Johnson is governed by the values set forth in Our Credo, created by General Robert Wood Johnson in 1943. These values have guided us for many years and will

More information

XARELTO BLEEDING RISKS AND POTENTIALLY FATAL SIDE EFFECTS

XARELTO BLEEDING RISKS AND POTENTIALLY FATAL SIDE EFFECTS XARELTO BLEEDING RISKS AND POTENTIALLY FATAL SIDE EFFECTS 1 In 2011, a new anticoagulant drug was approved by the U.S. Food and Drug Administration (FDA). The new drug Xarelto was marketed as a more convenient

More information

By BARRY MEIER. implant, maker of. warnings. like an patients. if a device,

By BARRY MEIER. implant, maker of. warnings. like an patients. if a device, The Implants Loophole By BARRY MEIER Published: December 16, 20100 A recently recalled artificial hip made by a unit of Johnson & Johnson, designed to last 15 years or more, is failing worldwide at unusually

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA : CRIMINAL NO. v.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA : CRIMINAL NO. v. IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA : CRIMINAL NO. v. : DATE FILED: NOVARTIS PHARMACEUTICALS : VIOLATION: CORPORATION 21 U.S.C. 331(a),

More information

Adoption of Information Technology in Healthcare: Benefits & Constraints

Adoption of Information Technology in Healthcare: Benefits & Constraints Adoption of Information Technology in Healthcare: Benefits & Constraints A WiredFox Technologies White Paper 2 Adoption of Information Technology in Healthcare: Benefits & Constraints By Jeff Yelton 3

More information

Main Page Search August 25, 2010

Main Page Search August 25, 2010 1 of 6 8/25/2010 5:22 PM Main Page Search August 25, 2010 Association News Features/Substantive Law Spotlight/Profiles Departments Classifieds The Hennepin Lawyer Kenneth Ross August 24, 2010 Headlines

More information

GlaxoSmithKline Consumer Healthcare Australia Pty Ltd (ABN: 68 603 310 292) TERMS AND CONDITIONS OF SALE (Effective as at 7 th September 2015)

GlaxoSmithKline Consumer Healthcare Australia Pty Ltd (ABN: 68 603 310 292) TERMS AND CONDITIONS OF SALE (Effective as at 7 th September 2015) GlaxoSmithKline Consumer Healthcare Australia Pty Ltd (ABN: 68 603 310 292) TERMS AND CONDITIONS OF SALE (Effective as at 7 th September 2015) 1. DEFINITIONS In these terms and conditions: (1) Adverse

More information

WAIVER OF FUTURE CONFLICTS OF INTEREST: PERMITTED IN GEORGIA?

WAIVER OF FUTURE CONFLICTS OF INTEREST: PERMITTED IN GEORGIA? WAIVER OF FUTURE CONFLICTS OF INTEREST: PERMITTED IN GEORGIA? Middle District of Georgia Bankruptcy Law Institute Friday, September 7, 2007 Macon, Georgia Clark D. Cunningham W. Lee Burge Professor of

More information

the sick funds payments are hospital focused and do not sufficiently upset out patient care or rehabilitation or psychiatric or homecare.

the sick funds payments are hospital focused and do not sufficiently upset out patient care or rehabilitation or psychiatric or homecare. Bargain Medicine: Anatomy of a High Quality Healthcare System, Valiantly Operating with Inadequate Funding, or Socialism in Actions: How to over Promise and Under Deliver ; Mr. Kenneth Abramowitz, Managing

More information

Virtual Mentor American Medical Association Journal of Ethics January 2012, Volume 14, Number 1: 31-34.

Virtual Mentor American Medical Association Journal of Ethics January 2012, Volume 14, Number 1: 31-34. Virtual Mentor American Medical Association Journal of Ethics January 2012, Volume 14, Number 1: 31-34. HEALTH LAW The National Childhood Vaccine Injury Act and the Supreme Court s Interpretation Valarie

More information

Standards of. Conduct. Important Phone Number for Reporting Violations

Standards of. Conduct. Important Phone Number for Reporting Violations Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,

More information

Under Coverages, the following coverages are added:

Under Coverages, the following coverages are added: And Crisis Management Insurance Endorsement Policy Period Effective Date Policy Number Insured Name of Company Date Issued This Endorsement applies to the following forms: Coverages Expenses For Life Science

More information

Introduction to Compliance with FDA Labeling and Advertising Requirements

Introduction to Compliance with FDA Labeling and Advertising Requirements Introduction to Compliance with FDA Labeling and Advertising Requirements Second Annual Pharmaceutical Industry Regulatory and Compliance Summit Dick Kenny FDA History Basic function of government Oldest

More information

SUPPLEMENT. Product Safety The CEO s Duty to Report Defects Immediately to the Government Managing the Recall that May Follow

SUPPLEMENT. Product Safety The CEO s Duty to Report Defects Immediately to the Government Managing the Recall that May Follow SUPPLEMENT Product Safety The CEO s Duty to Report Defects Immediately to the Government Managing the Recall that May Follow Joseph M. Beck Partner Overview of the Consumer Product Safety Act (the CPSA

More information

Understanding Trust in OTC Medicines: Consumer and Healthcare Provider Perspectives

Understanding Trust in OTC Medicines: Consumer and Healthcare Provider Perspectives Understanding Trust in OTC Medicines: Consumer and Healthcare Provider Perspectives March 6, 2013 Table of Contents I. Over-the-Counter Medicines Today: Value, Savings, and Self-Care Trends II. Understanding

More information

SELECT SERVICES FLAT FEE REPRESENTATION AGREEMENT page 1 of 8

SELECT SERVICES FLAT FEE REPRESENTATION AGREEMENT page 1 of 8 Utah Family Law, LC Tel. No. 801-466-9277 E-mail: eric@divorceutah.com Attorney Eric K. Johnson - Attorney Russell W. Hartvigsen Mail: 2666 South 2000 East, Suite 101 Salt Lake City Utah 84109 REMEMBER:

More information

Key Provisions of Tennessee Senate Bill 200 Effective July 1, 2014, through July 1, 2016

Key Provisions of Tennessee Senate Bill 200 Effective July 1, 2014, through July 1, 2016 2014 Construction of Statute Definition of Injury (Causation) Revises Section 50-6-116, Construction of Chapter, to indicate that for dates of injury on or after July 1, 2014, the chapter should no longer

More information

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings Author: Attorney Dan A. Riegleman N63 W23965 Main Street Sussex, Wisconsin 53089 Prepared: 06/01/10 WHITE PAPER: DR2504 Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings There are

More information

PUBLIC ENTITY RISK MANAGEMENT AUTHORITY MEMORANDUM OF WORKERS COMPENSATION AND EMPLOYERS LIABILITY COVERAGE

PUBLIC ENTITY RISK MANAGEMENT AUTHORITY MEMORANDUM OF WORKERS COMPENSATION AND EMPLOYERS LIABILITY COVERAGE PUBLIC ENTITY RISK MANAGEMENT AUTHORITY MEMORANDUM OF WORKERS COMPENSATION AND EMPLOYERS LIABILITY COVERAGE FOR THE PERIOD JULY 1, 2015 TO JUNE 30, 2016 EFFECTIVE: JULY 1, 2015 PUBLIC ENTITY RISK MANAGEMENT

More information

DEPUY HIP REPLACEMENTS: WHAT YOU NEED TO KNOW ABOUT THEM

DEPUY HIP REPLACEMENTS: WHAT YOU NEED TO KNOW ABOUT THEM DEPUY HIP REPLACEMENTS: WHAT YOU NEED TO KNOW ABOUT THEM 1 As people get older, some of their bones actually do get weary and tired. Sometimes, bones and joints need to be replaced by doctors to improve

More information

CODE OF ETHICS AND PROFESSIONAL CONDUCT

CODE OF ETHICS AND PROFESSIONAL CONDUCT CODE OF ETHICS AND PROFESSIONAL CONDUCT Mission To provide adults, caregivers and families with programs and services promoting an enhanced quality of life. Family Alliance, Inc. has a clearly stated charitable

More information

Ministry of Labour and Social Policy LAW ON VOLUNTARY FULLY FUNDED PENSION INSURANCE (189347.11)

Ministry of Labour and Social Policy LAW ON VOLUNTARY FULLY FUNDED PENSION INSURANCE (189347.11) Ministry of Labour and Social Policy LAW ON VOLUNTARY FULLY FUNDED PENSION INSURANCE 1 Table of Contents CHAPTER 1 GENERAL PROVISIONS... 3 CHAPTER 2 VOLUNTARY PENSION FUNDS... 7 CHAPTER 3 PENSION COMPANIES

More information

TEXTURA AUSTRALASIA PTY LTD ACN 160 777 088 ( Textura ) CONSTRUCTION PAYMENT MANAGEMENT SYSTEM TERMS AND CONDITIONS OF USE

TEXTURA AUSTRALASIA PTY LTD ACN 160 777 088 ( Textura ) CONSTRUCTION PAYMENT MANAGEMENT SYSTEM TERMS AND CONDITIONS OF USE TEXTURA AUSTRALASIA PTY LTD ACN 160 777 088 ( Textura ) CONSTRUCTION PAYMENT MANAGEMENT SYSTEM TERMS AND CONDITIONS OF USE Welcome to the Textura Construction Payment Management ( CPM ) System. By clicking

More information

Aetna Life Insurance Company

Aetna Life Insurance Company Aetna Life Insurance Company Hartford, Connecticut 06156 Amendment (GR-GrpAppealsER 03) Policyholder: Group Policy No.: Effective Date: GP- This Amendment is effective on the later of: July 12, 2012; or

More information

Arthritis Pain Management after Merck s Withdrawal of Vioxx Survey Results

Arthritis Pain Management after Merck s Withdrawal of Vioxx Survey Results Arthritis Pain Management after Merck s Withdrawal of Vioxx/Survey Results MedicineNet Health Research Survey Report Arthritis Pain Management after Merck s Withdrawal of Vioxx Survey Results Prepared

More information

Cyber Risk: Global Warning? by Cinzia Altomare, Gen Re

Cyber Risk: Global Warning? by Cinzia Altomare, Gen Re Cyber Risk: Global Warning? by Cinzia Altomare, Gen Re Global Warning It is a matter of time before there is a major cyber attackon the global financial system and the public needs to invest heavily in

More information

Whistleblower Cases an Overview

Whistleblower Cases an Overview Whistleblower Cases an Overview by John P. Leader, Esq. 1 1 John is a former Assistant United States Attorney, where he practiced for nine (9) years in the Criminal Division of the Arizona Office. Page

More information

Ch. 103 GOVERNANCE AND MANAGEMENT 28 CHAPTER 103. GOVERNANCE AND MANAGEMENT A. GOVERNING PROCESS... 103.1

Ch. 103 GOVERNANCE AND MANAGEMENT 28 CHAPTER 103. GOVERNANCE AND MANAGEMENT A. GOVERNING PROCESS... 103.1 Ch. 103 GOVERNANCE AND MANAGEMENT 28 CHAPTER 103. GOVERNANCE AND MANAGEMENT Subchap. Sec. A. GOVERNING PROCESS... 103.1 Cross References This chapter cited in 28 Pa. Code 101.67 (relating to access by

More information

Real Estate Agent Website Linking Agreement

Real Estate Agent Website Linking Agreement Real Estate Agent Website Linking Agreement Please fill in this form and fax it to the Toll Brothers Marketing Department Fax # - (215) 938-8217 [Date] [Address] [Telephone] Fax: Attn: [Name and title]

More information

False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1

False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1 False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1 When Do False Claims Laws Apply? The federal False Claims Act (FCA) applies to any requests for payment from

More information

Disciplinary and Dismissals Policy

Disciplinary and Dismissals Policy Policy Purpose/statement/reason for being Disciplinary and Dismissals Policy E.G - MIP is designed to strengthen the effectiveness of individual s contribution to the Council s success. Purpose The Disciplinary

More information

SCAN Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005

SCAN Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005 Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005 Approver Approval Stage Date Chris Zorn Approval Event (Authoring) 12/09/2013 Nancy Monk Approval Event

More information

PUBLISHED AS A PUBLIC SERVICE BY THE OFFICE OF DISCIPLINARY COUNSEL

PUBLISHED AS A PUBLIC SERVICE BY THE OFFICE OF DISCIPLINARY COUNSEL This information has been prepared for persons who wish to make or have made a complaint to The Lawyer Disciplinary Board about a lawyer. Please read it carefully. It explains the disciplinary procedures

More information

Drug and Alcohol Testing of Doctors. Medical Negligence Lawsuits. Initiative Statute.

Drug and Alcohol Testing of Doctors. Medical Negligence Lawsuits. Initiative Statute. Proposition 46 Drug and Alcohol Testing of Doctors. Medical Negligence Lawsuits. Initiative Statute. Yes/No Statement A YES vote on this measure means: The cap on medical malpractice damages for such things

More information

CNA and NSO Risk Control Self-assessment Checklist for Nurse Practitioners 1. Self-assessment topic Yes No Actions needed to reduce risks

CNA and NSO Risk Control Self-assessment Checklist for Nurse Practitioners 1. Self-assessment topic Yes No Actions needed to reduce risks Risk Control Self-assessment Checklist for Nurse Practitioners This checklist is designed to help nurse practitioners evaluate risk exposures associated with their current practice. For additional nurse

More information

CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656

CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656 CALIFORNIA FALSE CLAIMS ACT GOVERNMENT CODE SECTION 12650-12656 12650. (a) This article shall be known and may be cited as the False Claims Act. (b) For purposes of this article: (1) "Claim" includes any

More information

Ethical Corporate Management Operating Procedures and Conduct Guide

Ethical Corporate Management Operating Procedures and Conduct Guide Ethical Corporate Management Operating Procedures and Conduct Guide Article 1. Goal Based on the principles of fairness, honesty, credibility and transparency in business activities, in order to implement

More information

Master Software Purchase Agreement

Master Software Purchase Agreement Master Software Purchase Agreement This Master Software Purchase Agreement ( Agreement ) is entered into as of Wednesday, March 12, 2014 (the Effective Date ) by and between with principal offices at (

More information

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA Codification District of Columbia Official Code 2001 Edition 2007 Winter Supp. West Group Publisher To amend AN ACT To provide for regulation of certain

More information

ASSEMBLY BILL No. 597

ASSEMBLY BILL No. 597 AMENDED IN ASSEMBLY APRIL 14, 2015 california legislature 2015 16 regular session ASSEMBLY BILL No. 597 Introduced by Assembly Member Cooley February 24, 2015 An act to amend Sections 36 and 877 of, and

More information

What Trustees Should Know About Florida s New Attorneys Fee Statute. By David P. Hathaway and David J. Akins. Introduction

What Trustees Should Know About Florida s New Attorneys Fee Statute. By David P. Hathaway and David J. Akins. Introduction What Trustees Should Know About Florida s New Attorneys Fee Statute By David P. Hathaway and David J. Akins Introduction More and more lawsuits are filed in Florida alleging that the trustee of a trust

More information

Agreement for Professional Emergency Services. professional emergency and related services provided at (hospital name) Hospital be

Agreement for Professional Emergency Services. professional emergency and related services provided at (hospital name) Hospital be Agreement for Professional Emergency Services This Agreement, made and effective on (effective date) by and between (name of hospital) Hospital, Inc., located at (address of hospital), (city, state and

More information

NOTICE TO THE INDIVIDUAL SIGNING THE ILLINOIS STATUTORY SHORT FORM POWER OF ATTORNEY FOR HEALTH CARE

NOTICE TO THE INDIVIDUAL SIGNING THE ILLINOIS STATUTORY SHORT FORM POWER OF ATTORNEY FOR HEALTH CARE NOTICE TO THE INDIVIDUAL SIGNING THE ILLINOIS STATUTORY SHORT FORM POWER OF ATTORNEY FOR HEALTH CARE PLEASE READ THIS NOTICE CAREFULLY. The form that you will be signing is a legal document. It is governed

More information

ASSEMBLY BILL No. 597

ASSEMBLY BILL No. 597 california legislature 2015 16 regular session ASSEMBLY BILL No. 597 Introduced by Assembly Member Cooley February 24, 2015 An act to amend Sections 36 and 877 of, and to add Chapter 6 (commencing with

More information

The Impact of Public Relations. by JenniferWinningham-Floden. directed toward gaining public understanding and acceptance. Public relations usually

The Impact of Public Relations. by JenniferWinningham-Floden. directed toward gaining public understanding and acceptance. Public relations usually The Impact of Public Relations by JenniferWinningham-Floden According to DefineThat.com, public relations is a form of communication primarily directed toward gaining public understanding and acceptance.

More information

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA

AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA AN ACT IN THE COUNCIL OF THE DISTRICT OF COLUMBIA To amend the District of Columbia Procurement Practices Act of 1985 to make the District s false claims act consistent with federal law and thereby qualify

More information

Review of insolvency engagements questionnaire

Review of insolvency engagements questionnaire Review of insolvency engagements questionnaire Introduction This questionnaire is to be used for formal insolvency engagements under the Corporations Act and Bankruptcy Act. The questionnaire is based

More information

How Reputation Management Services With PYI Will Protect Your Investment!

How Reputation Management Services With PYI Will Protect Your Investment! How Reputation Management Services With PYI Will Protect Your Investment! Why Is Reputation Management Important? Irrespective of your business type or size, Google and the Internet has become the world

More information

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014 I. Statement of Policy UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Revised as of March 3, 2014 Universal Insurance Holdings, Inc. ( UIH ) and its subsidiaries (collectively,

More information

BILLING INFORMATION AND ASSIGNMENT OF BENEFITS

BILLING INFORMATION AND ASSIGNMENT OF BENEFITS BILLING INFORMATION AND ASSIGNMENT OF BENEFITS Facility: Northpoint Radiation Center Pro Physicians Clinic PA Physician: Timothy D. Nichols, M.D. PA, Board Certified Radiation Oncology Wilhelm J. Lubbe,

More information

PRODUCTS LIABILITY. Westlaw Journal Formerly Andrews Litigation Reporter

PRODUCTS LIABILITY. Westlaw Journal Formerly Andrews Litigation Reporter Westlaw Journal Formerly Andrews Litigation Reporter PRODUCTS LIABILITY Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 22, ISSUE 3 / APRIL 2011 Expert Analysis New CPSC Database

More information

Individual Pharmacist Professional Liability Insurance Policy

Individual Pharmacist Professional Liability Insurance Policy THIS IS A LEGAL CONTRACT -- PLEASE READ THIS CAREFULLY -- Individual Pharmacist Professional Liability Insurance Policy Table of Contents Page DEFINITIONS... 1 PROFESSIONAL LIABILITY COVERAGE... 3 SUPPLEMENTAL

More information

Liquor. (Occurrence Form)

Liquor. (Occurrence Form) Liquor LIABILITY INSURANCE POLICY (Occurrence Form) 95A Turnpike Road Westborough, MA 01581 (508) 366-1140 THIS POLICY JACKET WITH THE Liquor LIABILITY POLICY FORM, DECLARATIONS PAGE AND ENDORSEMENTS,

More information

If You Paid for Vioxx Before October 1, 2004,

If You Paid for Vioxx Before October 1, 2004, UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA If You Paid for Vioxx Before October 1, 2004, You May Be Able To Get Money Back A Federal Court authorized this Notice. It is not a solicitation

More information

Ethical Issues Facing Attorneys Representing the Incapacitated Seminar: Advanced Nursing Home Litigation: Changing the Paradigm Date: 04/26/07

Ethical Issues Facing Attorneys Representing the Incapacitated Seminar: Advanced Nursing Home Litigation: Changing the Paradigm Date: 04/26/07 Rhonda Hill Wilson, Esquire Law Office of Rhonda Hill Wilson, PC Philadelphia, PA Ethical Issues Facing Attorneys Representing the Incapacitated Seminar: Advanced Nursing Home Litigation: Changing the

More information

ADVANCE DIRECTIVE VOLUME 19 SPRING 2010 PAGES 306-315. The Effect of Medical Malpractice. Jonathan Thomas *

ADVANCE DIRECTIVE VOLUME 19 SPRING 2010 PAGES 306-315. The Effect of Medical Malpractice. Jonathan Thomas * ANNALS OF HEALTH LAW ADVANCE DIRECTIVE VOLUME 19 SPRING 2010 PAGES 306-315 The Effect of Medical Malpractice Jonathan Thomas * I. INTRODUCTION: WHAT IS MEDICAL MALPRACTICE Every year, medical malpractice

More information

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT I. Introduction This Code of Conduct (the "Code") sets out basic principles to guide the day-today business activities of directors, officers

More information

Selling/Closing a Medical Practice

Selling/Closing a Medical Practice Selling/Closing a Medical Practice This publication is a snapshot of South Carolina laws, regulations and best practices as of July 2009. The material presented is likely to evolve and change from year

More information

Verbalize knowledge of laws and policies for administration of prescribed and over the counter medication to students.

Verbalize knowledge of laws and policies for administration of prescribed and over the counter medication to students. Medication Administration for Non-Licensed School Staff Canton City Schools School Health Issues: A federal mandate created in the 1970s obligated schools to provide children with medical services, including

More information

CHILDREN AND YOUNG PEOPLE SERVICE ALCOHOL, DRUG OR OTHER SUBSTANCE MISUSE OR ABUSE POLICY

CHILDREN AND YOUNG PEOPLE SERVICE ALCOHOL, DRUG OR OTHER SUBSTANCE MISUSE OR ABUSE POLICY CHILDREN AND YOUNG PEOPLE SERVICE ALCOHOL, DRUG OR OTHER SUBSTANCE MISUSE OR ABUSE POLICY KirkleesEdnet/Management/HumanResources APRIL 2008 Prepared by: Human Resources Strategy Unit Revised: November

More information

ORVANA MINERALS CORP. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS. October 2, 2013

ORVANA MINERALS CORP. CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS. October 2, 2013 ORVANA MINERALS CORP CODE OF BUSINESS CONDUCT AND ETHICS ADOPTED BY THE BOARD OF DIRECTORS October 2, 2013 -2- CODE OF BUSINESS CONDUCT AND ETHICS Orvana Minerals Corp is a publicly-traded Canadian company

More information

HIPAA Omnibus Notice of Privacy Practices Effective Date: March 03, 2012 Revised on: July 1, 2015

HIPAA Omnibus Notice of Privacy Practices Effective Date: March 03, 2012 Revised on: July 1, 2015 HIPAA Omnibus Notice of Privacy Practices Effective Date: March 03, 2012 Revised on: July 1, 2015 Mobile Physician Group PC 231 High Street Suite 1, Mount Holly, NJ 08060 1-855-MPG-DOCS THIS NOTICE DESCRIBES

More information

company policy number 0001 LEGAL AND ETHICAL CONDUCT

company policy number 0001 LEGAL AND ETHICAL CONDUCT company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest

More information

What to Do When Your Witness Testimony Doesn t Match His or Her Declaration

What to Do When Your Witness Testimony Doesn t Match His or Her Declaration What to Do When Your Witness Testimony Doesn t Match His or Her Declaration Russell R. Yurk Jennings, Haug & Cunningham, L.L.P. 2800 N. Central Avenue, Suite 1800 Phoenix, AZ 85004-1049 (602) 234-7819

More information

GLOSSARY OF SELECTED LEGAL TERMS

GLOSSARY OF SELECTED LEGAL TERMS GLOSSARY OF SELECTED LEGAL TERMS Sources: US Courts : http://www.uscourts.gov/library/glossary.html New York State Unified Court System: http://www.nycourts.gov/lawlibraries/glossary.shtml Acquittal A

More information

CODE OF CONDUCT. Providers, Suppliers and Contractors

CODE OF CONDUCT. Providers, Suppliers and Contractors CODE OF CONDUCT Providers, Suppliers and Contractors Table of Contents Code of Conduct... Honesty and integrity... Quality and Service... Responsibilities of Providers, Suppliers and Contractors... Compliance

More information

Physicians liability for off-label prescriptions

Physicians liability for off-label prescriptions Off-Label This is the third and final piece to our three-part series on off-label drug use Physicians liability for off-label prescriptions James B. Riley, Jr. P. Aaron Basilius It is estimated that between

More information

Electronic Health Record Sharing System Bill. Contents. Part 1. Preliminary. 1. Short title and commencement... C1203. 2. Interpretation...

Electronic Health Record Sharing System Bill. Contents. Part 1. Preliminary. 1. Short title and commencement... C1203. 2. Interpretation... C1193 Electronic Health Record Sharing System Bill Contents Clause Page Part 1 Preliminary 1. Short title and commencement... C1203 2. Interpretation... C1203 3. Substitute decision maker... C1213 4. Ordinance

More information

Today I will discuss medical negligence following a number of recent high profile cases and inquests.

Today I will discuss medical negligence following a number of recent high profile cases and inquests. Tipp FM Legal Slot 29 th May 2012 Medical Negligence John M. Lynch, Principal Today I will discuss medical negligence following a number of recent high profile cases and inquests. Firstly, what is Medical

More information

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

Drug and Alcohol Testing of Doctors. Medical Negligence Lawsuits. Initiative Statute.

Drug and Alcohol Testing of Doctors. Medical Negligence Lawsuits. Initiative Statute. osition Official Title and Summary Prepared by the Attorney General Requires drug and alcohol testing of doctors and reporting of positive test to the California Medical Board. Requires Board to suspend

More information

NOTICE OF PRIVACY PRACTICES TEMPLATE. Sections highlighted in yellow are optional sections, depending on if applicable

NOTICE OF PRIVACY PRACTICES TEMPLATE. Sections highlighted in yellow are optional sections, depending on if applicable NOTICE OF PRIVACY PRACTICES TEMPLATE Sections highlighted in yellow are optional sections, depending on if applicable Original Date: ##/##/#### Revised per HIPAA Omnibus Rule ##/##/#### Revised Date Implementation:

More information

POLICY NO. 3-80 LEGAL DEFENSE BENEFIT

POLICY NO. 3-80 LEGAL DEFENSE BENEFIT FLORIDA POLICE BENEVOLENT ASSOCIATION, INC. POLICY NO. 3-80 LEGAL DEFENSE BENEFIT BACKGROUND: In order to provide legal defense benefits to the members of Florida P.B.A., the Board of Directors hereby

More information

Session 11b Product Defects & Liability. Sherry Kao

Session 11b Product Defects & Liability. Sherry Kao Session 11b Product Defects & Liability Sherry Kao 2015/06/26 Product Defects & Liability Prepared by Sherry Kao Aon Risk Solutions 1 3 4 2 5 Agenda Types of product defect Causes of product defect Products

More information

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs

More information

Liability Insurance (D&O) Presented by Caroline Yeo

Liability Insurance (D&O) Presented by Caroline Yeo Directors Beyond Insurance & Officers Liability Insurance (D&O) Presented by Caroline Yeo The Structure of D&O Insurance Covered claim against directors and officers Covered securities claim against the

More information

LIFE INSURANCE. Product Disclosure Statement

LIFE INSURANCE. Product Disclosure Statement LIFE INSURANCE Product Disclosure Statement This product and Product Disclosure Statement are issued by Suncorp Life & Superannuation Limited ABN 87 073 979 530 AFSL 229880 under the brand, AAMI. Contents

More information

It s More Than a Tag Line

It s More Than a Tag Line Smart In Your World It s More Than a Tag Line Arent Fox Is Arent Fox Is Finding Truth False Claims Act TO RENDER QUAlITy HEAlTH CARE WITH A SpECIAl FOCUS ON THE poor AND THE VUlNERABlE. In the late 19th

More information

INVESTMENT ADVISER REPRESENTATIVE AGREEMENT

INVESTMENT ADVISER REPRESENTATIVE AGREEMENT INVESTMENT ADVISER REPRESENTATIVE AGREEMENT This investment adviser representative agreement ( Agreement ), made as of, 20, is between Partners for Prosperity, Inc., a Nevada corporation, with the principal

More information

Retail Client Agreement Investment, Insurance and Mortgage Services

Retail Client Agreement Investment, Insurance and Mortgage Services Retail Client Agreement Investment, Insurance and Mortgage Services Lewis Investment 41 Commercial Road Poole Dorset BH14 0HU 1. Introduction The purpose of this agreement is to set out the basis on which

More information

J&J Said to Offer Implant Pact That May Reach $2 Billion

J&J Said to Offer Implant Pact That May Reach $2 Billion J&J Said to Offer Implant Pact That May Reach $2 Billion By Jef Feeley and David Voreacos - Jan 19, 2013 Johnson & Johnson (JNJ), which is fighting more than 10,000 lawsuits over its recalled hip implants,

More information

Cooper Hurley Injury Lawyers

Cooper Hurley Injury Lawyers Cooper Hurley Injury Lawyers 2014 Granby Street, Suite 200 Norfolk, VA, 23517 (757) 455-0077 (866) 455-6657 (Toll Free) YOUR RIGHTS WHEN YOU ARE INJURED ON THE RAILROAD Cooper Hurley Injury Lawyers 2014

More information

If you are signing for a minor child, you refers to your child throughout the consent document.

If you are signing for a minor child, you refers to your child throughout the consent document. CONSENT TO PARTICIPATE IN A CLINICAL RESEARCH STUDY Adult Patient or Parent, for Minor Patient INSTITUTE: National Cancer Institute PRINCIPAL INVESTIGATOR: Raffit Hassan, M.D. STUDY TITLE: Tissue Procurement

More information

VANDA PHARMACEUTICALS INC.

VANDA PHARMACEUTICALS INC. VANDA PHARMACEUTICALS INC. CODE OF ETHICS AND BUSINESS CONDUCT (As of May 22, 2014) 1. POLICY STATEMENT The reputation and integrity of Vanda Pharmaceuticals Inc. (the Company ) are valuable assets that

More information

HIPAA PRIVACY NOTICE PLEASE REVIEW IT CAREFULLY

HIPAA PRIVACY NOTICE PLEASE REVIEW IT CAREFULLY HIPAA PRIVACY NOTICE THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. INTRODUCTION PLEASE REVIEW IT CAREFULLY Moriarty

More information